Privacy Policy

This Privacy Policy describes how Social Market, Inc DBA MintLocke (“MintLocke,” “we,” “us,” or “our”) collects, uses, and shares information about you when you use our website, mobile application, and related services (collectively, the “Services”). By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly to us, including:

• Account Information: Email address, username, and password when you create an account
• Wallet Information: Public wallet addresses you connect to our Services (we never collect or store your private keys)
• Payment Information: When you subscribe to a paid tier, payment information is collected and processed by our payment processor, Stripe. We do not store your full credit card number or payment credentials on our servers.
• Configuration Preferences: Your selected goals, automation parameters, target allocations, and other settings
• Communications: Information you provide when you contact us for support or feedback

1.2 Information We Collect Automatically

When you use our Services, we automatically collect certain information through cookies, pixels, and similar technologies, including:

Device Information: Device type, operating system, browser type, screen resolution, and unique device identifiers
Usage Information: Pages viewed, features used, actions taken, clicks, scrolls, and time spent on the Services
Log Information: IP address, access times, referring URLs, and pages visited before and after using our Services
Location Information: General geographic location based on IP address (city, region, country)

1.3 Blockchain Information

When you connect your wallet and use our Services, we interact with public blockchain networks. All transactions executed through our Services are recorded on public blockchains and are visible to anyone. This includes your public wallet address, transaction amounts, and the smart contracts you interact with. We do not control blockchain networks and cannot delete or modify blockchain data.

2. Third-Party Services and Technologies

We use the following third-party services to operate, analyze, and improve our Services. These services may collect information about you as described below:

2.1 Firebase (Google)

We use Firebase, a platform provided by Google, for authentication, database services, and hosting. Firebase may collect device identifiers, IP addresses, and usage data. Firebase’s data practices are governed by Google’s Privacy Policy. For more information, visit: https://firebase.google.com/support/privacy

2.2 Google Analytics

We use Google Analytics to collect and analyze information about how users interact with our Services. Google Analytics uses cookies and similar technologies to collect information such as how often users visit our site, what pages they visit, and what other sites they used prior to coming to our site. We use this information to improve our Services. Google Analytics collects the IP address assigned to you on the date you visit our site, but not your name or other identifying information. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout

2.3 Google Tag Manager

We use Google Tag Manager to manage and deploy marketing and analytics tags on our website. Google Tag Manager itself does not collect personal information, but it facilitates the deployment of other tags that may collect data as described in this policy.

2.4 Go High Level

We use Go High Level for customer relationship management (CRM), email marketing, and automated communications. When you provide your email address or interact with our marketing communications, Go High Level may collect your email address, name, communication preferences, and information about your interactions with our emails (such as opens and clicks). For more information, visit Go High Level’s privacy policy at: https://www.gohighlevel.com/privacy-policy

2.5 Stripe

We use Stripe to process payments for subscription services. When you make a payment, Stripe collects payment card information, billing address, and other information necessary to process your transaction. Stripe may also collect information about your device and browser to prevent fraud. We do not have access to your full payment card number. Stripe’s collection and use of your information is governed by Stripe’s Privacy Policy: https://stripe.com/privacy

2.6 Summary of Third-Party Data Collection

3. Cookies and Tracking Technologies

We and our third-party partners use cookies, pixels, and similar tracking technologies to collect information about your use of our Services. These technologies help us:

• Remember your preferences and settings
• Authenticate your identity and maintain your session
• Analyze how our Services are used and improve performance
• Deliver and measure the effectiveness of marketing campaigns
• Prevent fraud and enhance security

3.1 Types of Cookies We Use

• Essential Cookies: Required for the Services to function properly, including authentication and security
• Analytics Cookies: Help us understand how visitors interact with our Services (e.g., Google Analytics)
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your activity across websites to deliver relevant advertising

3.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can typically find these settings in the “Options” or “Preferences” menu of your browser. You can also use the following links to manage cookies for common browsers:

• Google Chrome: chrome://settings/cookies
• Mozilla Firefox: about:preferences#privacy
• Safari: Preferences > Privacy
• Microsoft Edge: edge://settings/privacy

Note: Disabling certain cookies may affect the functionality of our Services.

4. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services
• Execute your configured automation goals (Accumulate, Earn, Rebalance, Protect)
• Process transactions and manage your vault
• Process subscription payments through Stripe
• Send you technical notices, updates, security alerts, and support messages
• Send you marketing communications (with your consent, where required)
• Respond to your comments, questions, and customer service requests
• Monitor and analyze trends, usage, and activities using Google Analytics
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Comply with legal obligations

5. How We Share Your Information

We may share your information in the following circumstances:

• Service Providers: With the third-party service providers described in Section 2, who help us operate our Services
• Blockchain Networks: Transactions are broadcast to public blockchain networks and are publicly visible
• DeFi Protocols: When executing your automation goals, we interact with third-party DeFi protocols on your behalf
• Legal Requirements: When required by law, subpoena, or other legal process, or in response to valid requests by public authorities
• Protection of Rights: To protect the rights, privacy, safety, or property of MintLocke, you, or others
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business

We do not sell your personal information to third parties.

6. Data Security

We implement appropriate technical and organizational measures to protect the information we collect, including encryption in transit (TLS/SSL), secure cloud infrastructure (Firebase), and access controls. However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security of your data.

Important: We operate on a non-custodial basis. We never have access to your private keys. You are solely responsible for maintaining the security of your wallet and private keys.

7. Data Retention

We retain your personal information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account information: Retained while your account is active and for a reasonable period thereafter
• Transaction records: Retained as required by applicable law (typically 7 years for financial records)
• Analytics data: Google Analytics data is retained according to our configured retention settings (typically 26 months)
• Marketing data: Retained until you unsubscribe or request deletion

8. Your Rights and Choices

8.1 Account Information

You may update or correct your account information at any time by logging into your account settings. You may also request deletion of your account by contacting us at [email protected], though we may retain certain information as required by law or for legitimate business purposes.

8.2 Marketing Communications

You may opt out of receiving marketing emails from us by clicking the “unsubscribe” link in any marketing email or by contacting us. If you opt out, we may still send you non-promotional communications, such as those about your account, transactions, or our ongoing business relationship.

8.3 Cookies and Tracking

You can manage cookies and tracking as described in Section 3.2. Additionally:

• Google Analytics Opt-out: Install the Google Analytics Opt-out Browser Add-on
• Do Not Track: Some browsers offer a “Do Not Track” feature. Our Services do not currently respond to Do Not Track signals.

8.4 Blockchain Data

Information recorded on public blockchains cannot be deleted or modified. This is a fundamental characteristic of blockchain technology and is outside of our control.

9. California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you
• Right to Delete: You may request that we delete your personal information, subject to certain exceptions
• Right to Correct: You may request that we correct inaccurate personal information
• Right to Opt Out of Sale/Sharing: We do not sell or share personal information for cross-context behavioral advertising
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To exercise your California privacy rights, please contact us at [email protected]. We may need to verify your identity before processing your request.

10. International Data Transfers

Your information may be transferred to and processed in the United States and other countries where our service providers operate, including Google (Firebase, Analytics) and Stripe. These countries may have data protection laws that are different from the laws of your country. By using our Services, you consent to the transfer of your information to these countries.

11. Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we have collected information from a child under 18, please contact us at [email protected].

12. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services, including DeFi protocols and wallet providers. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access, including:

• Wallet providers (MetaMask, Coinbase Wallet, etc.)
• DeFi protocols we integrate with
• Blockchain explorers and other tools

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. For material changes, we may also notify you by email or through a notice in our application. We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any modifications constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have any questions about this Privacy Policy, our data practices, or wish to exercise your privacy rights, please contact us at:

Social Market, Inc DBA MintLocke
110 E Houston St, 3rd Floor, Suite 725, San Antonio, TX 78205
Email: [email protected]